Privacy

Privacy Policy

Financial Professionals Pty. Ltd. and Investment Professionals Pty. Ltd. are signatories to the Financial Planning Association privacy policy, a copy of which can be obtained by contacting us by any of the methods detailed below. Our policy on the management of personal information
is as follows:

Type of personal information collected

As a financial planning organisation we are subject to certain legislative and regulatory requirements that necessitate us obtaining and holding detailed information that personally identifies you and/or contains information or an opinion about you (“personal information”).
In addition, our ability to provide you with a comprehensive financial planning and advice service is dependent on us obtaining certain personal information about you, including:
• Employment details and employment history;
• Details of your financial needs and objectives;
• Details of your current financial circumstances, including your assets and liabilities (both actual and potential), income, expenditure, insurance cover and superannuation;
• Details of your investment preferences and aversion or tolerance to risk;
• Information about your employment history, employment circumstances, family commitments and social security eligibility;
• Details of your current insurances;
• Details of your current estate planning.

Consequences of not providing the requested personal information

Failure to provide the personal information referred to above may expose you to higher risk in respect of the recommendations made to you and may affect the adequacy or appropriateness
of advice we give to you.

As we are required by the Corporations Act and Rules of Professional Conduct of the Financial Planning Association of Australia to collect sufficient information to ensure appropriate advice can be given in respect of recommendations made to our clients, if you elect not to provide us with the personal information referred to above, we may elect to terminate our relationship with you if we believe we are unable to provide you with a complete service.

Collection Policies

We will not collect any personal information about you except when you have knowingly provided that information to us or authorised a third party to provide that information to us.

Generally your personal information will be collected either at a face-to-face interview, over the telephone or by way of our confidential client data collection kit. From time to time additional
and/or updated personal information may be collected through one or more of these methods.

We will only collect, maintain and use personal information about you if it is necessary for us to adequately provide the services you have requested including:
• The preparation of your financial plan;
• The provision of financial planning advice to you;
• Making securities and investment recommendations;
• Reviewing your financial plan;
• Reviewing securities and investment recommendations.

Information Use & Disclosure Policy

We will not use or disclose personal information collected by us for any purpose other than:
• The purposes for which it was provided or secondary related purposes in circumstances where you would reasonably expect such use or disclosure; or
• Where you have consented to such disclosure; or
• Where the National Privacy Principles authorise use or disclosure where required or authorised under law, in circumstances relating to public health and safety and in connection with certain operations by or on behalf of an enforcement body.

We are required under the Rules of Professional Conduct of the Financial Planning Association of Australia to make certain information available for inspection by the FPA on request to ensure ongoing compliance with mandatory professional standards. This may involve the disclosure of
your personal information. We are also obliged pursuant to the Corporations Act to maintain certain transaction records and make those records available for inspection by the Australian Securities and Investments Commission.

We may use the personal information collected from you for the purpose of providing you with direct marketing material such as articles that may be of interest to you, however you may, by contacting us by any of the methods detailed below, request not to receive such information and
we will give effect to that request. Please allow 2 weeks for your request to be actioned.

We may disclose your Personal Information to superannuation fund trustees, insurance providers and product issuers for the purpose of giving effect to your financial plan and recommendations made by us.

In order to ensure that you receive a personal and tailored service, your personal information may be transferred to one of our authorised representatives who will be your primary point of contact with the organisation. It is a condition of our agreement with each of our representatives that they adopt and adhere to this privacy policy. You can be assured that your information will be maintained by a representative in accordance with this policy. If you have any concerns in
this regard, you should contact us by any of the methods detailed below.

We may disclose your personal information to external contractors for the following purposes: To provide services that relate to your financial plan but that we are not able to provide ourselves.
Examples are legal advice, insurance policies and provision of finance.
It is a condition of our agreement with each of our external contractors that they adopt and adhere to this privacy policy. You can be assured that your information will be maintained by any contractor to whom it is disclosed in accordance with this policy. If you have any concerns
in this regard, you should contact us by any of the methods noted at the end of this document.

In the event that we propose to sell our business we may disclose your personal information to potential purchasers for the purpose of them conducting due diligence investigations. Any such disclosure will be made in confidence and it will be a condition of that disclosure that no personal
information will be used or disclosed by them. In the event that the sale of our business is concluded, we may transfer your personal information to the purchaser of the business. As a client you will be advised of any such transfer.

document storage and security policies and practices

Your personal information is generally held in your client file. Information is also held in a computer database. We will at all times seek to ensure that the personal information collected and held by us is protected from misuse, loss, unauthorised access, modification or disclosure. At all times
your personal information is treated as confidential and any sensitive information is treated as highly confidential. All paper files are stored in lockable cabinets or rooms that are locked out of office hours. All record movements off premises are recorded in a central register. All computer-
based information is protected through the use of access passwords on each computer and screen saver passwords. Data is backed up each evening and stored securely off site.

In the event you cease to be a client of this organisation, any personal information which we hold about you will be maintained in a secure off site storage facility or computer database for a period of 7 years in order to comply with legislative and professional requirements, following
which time the information will be destroyed.

How you may gain access to your personal information

You may at any time request access to your personal information and we will (subject to the following exceptions) provide you with access to that information either by providing you with copies of the information requested, allowing you to inspect the information requested or
providing you with an accurate summary of the information held. We will, prior to providing access in accordance with this policy, require you to provide evidence of your identity.

We will not provide you access to personal information which would reveal any confidential formulae or the detail of any in house evaluative decision making process, but may instead provide you with the result of the formulae or process or an explanation of that result.
We will not provide you with access to your personal information if:
-Providing access would pose a serious threat to the life or health of a person;
-Providing access would have an unreasonable impact on the privacy of others;
-The request for access is frivolous or vexatious;
-The information related to existing or anticipated legal proceedings between us and would not be discoverable in those proceedings;
– Providing access would reveal our intentions in relation to negotiations with you in such a way as to prejudice those negotiations;
-Providing access would be unlawful;
-Denying access is required or authorised by or under law;
-Providing access would be likely to prejudice certain operations by or on behalf of an enforcement body or an enforcement body requests that access not be provided on the grounds of national security.
In the event we refuse you access to your personal information, we will provide you with an explanation for that refusal.

access and correction policies and procedures

We will endeavour to ensure that, at all times, the personal information that we hold about you is up to date and accurate. In the event that you become aware, or believe that any personal information we hold about you is inaccurate, incomplete or outdated, you should contact us and
provide evidence of the inaccuracy or incompleteness or out-datedness of the information. If we agree that the information requires correcting, we will take all reasonable steps to correct it.

If we do not agree that your personal information requires correcting, we must take reasonable steps to ensure that whenever your personal information is accessed or handled in the future, it is emphasised that you are not satisfied as to the accuracy or completeness of that information.

We will endeavour to respond to any request for access within 14-30 days depending on the complexity of the information and/or the request. If your request is urgent please indicate this clearly.

If you need to make a policy complaint

If you wish to complain about any breach or potential breach of this privacy policy or the National Privacy Principles, you should contact us and request that your complaint be directed to the Privacy Officer. Your complaint will be considered within 7 days and responded to. It
is our intention to use our best endeavours to resolve any complaint to your satisfaction, however, if you are unhappy with our response, you are entitled to contact the Office of the Privacy Commissioner who may investigate your complaint further.